E Providing Environmental Technical Support Since 1989 C

/R Incorporated

1 

MEMORANDUM 

TO: Melanie King, EPA OAQPS/SPPD/ESG 

FROM: Bradley Nelson, EC/R, Inc. 

DATE: August 31, 2009 

SUBJECT: Summary of the August 18, 2009 Meeting in Research Triangle Park, NC with 

Exterran and the U.S. Environmental Protection Agency to discuss the Proposed 

NESHAP for Existing Stationary RICE 

1.0 INTRODUCTION 

Exterran requested this meeting with EPA to discuss their comments on the proposed 

national emission standards for hazardous air pollutants (NESHAP) for existing stationary 

reciprocating internal combustion engines (RICE). Also at this meeting were representatives 

from Compressor Systems Inc. and J-W Power Company, and their legal counsel from the law 

firm of Bracewell & Giuliani. Exterran, J-W Power, and Compressor Systems, Inc. are the three 

largest operators of contract compression to the U.S. oil and gas industry. The companies 

estimate that contract compression comprises approximately one-third of the compression in the 

oil and gas industry. This meeting summary will be available in the docket for this rulemaking 

(Docket ID No. EPA-HQ-OAR-2008-0708). The proposed NESHAP for existing stationary 

RICE was published in the Federal Register on March 5, 2009 (74 FR 9698). 

2.0 ATTENDEES 

U.S. Environmental Protection Agency

Bob Wayland, OAQPS/SPPD/ESG 

Melanie King, OAQPS/SPPD/ESG 

Michael Horowitz, OGC (by phone) 

Exterran

Gerald Meinecke 

Mike Wasson 

Bill Bowes 

James Harrison (by phone) 

Kyle Jantzen (by phone) 
2 

Bracewell & Giuliani

Jeff Holmstead 

Rebecca Rentz 

Richard Alonso (by phone) 

JW Power Co.

John Dutton 

Compressor Systems Inc.

Levent Caglar 

David O’Leary 

EC/R Incorporated

Bradley Nelson 

3.0 SUMMARY OF MEETING 

The companies provided an agenda summarizing the issues that they wanted to discuss 

with EPA. A copy of the agenda is included in Attachment 1 of these meeting minutes. Jeff 

Holmstead began the meeting by stating that the companies represent small (<500 horsepower 

(HP)) natural gas fired engines located mostly at rural locations. 

The first topic of discussion was the subcategorization of engines located in rural areas. 

The industry representatives asked if EPA was considering using the urban and rural guidelines 

that were used for the Oil & Gas Production NESHAP. EPA responded that it is looking at the 

issue, but that no final decisions had been made. 

The industry group asked what management practices are being are being considered for 

the final rule for engines less than 500 HP at area sources. EPA stated it was looking at 

management practices that were provided in the comments, and asked industry which 

management practices reduce emissions from the engines. The industry group responded that the 

companies already have an operator defined management program used to prolong the life of the 

engine. These practices include: monitoring of the spark plugs and changing of the oil. Industry 

stated that many of the facilities test the oil to make sure the oil properties are sufficient for 

lubrication of the engine. Industry also stated that replacement of the oxygen sensor could also 

be used as a management practice. EPA agreed that these management practices are viable 

options, but stated that the management practices must have objective criteria that can be 

measured. Industry responded that there are a lot of variations in the type of engines and the 

operations associated with each engines so it is difficult to propose objective criteria. Industry 

stated that the management programs should be operator defined. Industry asked if oil 
3 

sweetening would be allowed in the final rule. EPA responded that the facility can petition for 

alternative compliance to the permitting authority by providing technical justification for oil 

sweetening. EPA asked that industry provide recommendations for management practices by 

October. 

The next issue that was discussed was startup, shutdown, and malfunction (SSM). 

Industry estimated that their engines have 3-4 shutdowns per month, and engines typically take 

approximately 15 minutes to heat up to temperature during startup. However, some engines in 

cold areas may take up to 45 minutes for startup. To address the SSM issue, industry suggested 

using the de minimis language from the Alabama Power court decision for natural gas RICE less 

than 500 HP. Other options suggested for SSM include: accounting for SSM emissions in the 

floor calculations; subcategorizing the SSM events and establishing separate limits; or work 

practices. Industry suggested that EPA could address the SSM issue by setting a not-to-exceed 

limit for SSM events for each month, or set a pound per hour limit for SSM events. EPA 

responded that no additional test information was received for these engines during the comment 

period. 

The next issue that was discussed was the test protocol letter that was sent to EPA by 

Bracewell & Giuliani that outlines the proposed collection of emissions test data for natural gasfired engines less than 500 HP to support the RICE NESHAP (See Attachment 2). Industry 

stated that they had three options: 

 Option 1 - provide as much test data as possible before October; 

 Option 2 - request and receive an extension of the rule and collect additional data; or 

 Option 3 - collect no data and challenge the final rule. 

Industry wants to ensure that if they choose Option 1 that the collected test data will be used by 

EPA to establish new limits. EPA responded that any data received in October would be 

included in the MACT floor analysis for the engines. Industry asked if the emission data should 

be provided in grams per brake horsepower-hour at full load. EPA stated that the tests should 

consider variability and provide data that is achieved in practice. 

Industry stated that most of the 2-stroke lean burn engines less than 500 HP are Ajax 

engines and that these engines do not produce enough heat to allow an oxidation catalyst to 

operate effectively. Industry stated that they currently have 14 engines that use a catalyst, but the 

use of a catalyst increases nitrogen oxides emissions. 
4 

Attachment 1 

Agenda for Exterran Meeting with EPA 

August 18, 2009 
5 
6 

Attachment 2 

Test Protocol Letter 

August 17, 2009